If My Short-Term Disability Claim Was Approved, Will My Long-Term Disability Claim Be Approved Too?
Not necessarily. In Mendoza v. First Unum Life Insurance Co., No. 25-3080 (9th Cir. Aug. 10, 2026), the Ninth Circuit held that payment of short-term disability benefits does not create a legal presumption that a claimant qualifies for long-term disability benefits.
Why can an insurer approve STD and later deny LTD?
In Mendoza v. First Unum Life Insurance Co., No. 25-3080 (9th Cir. Aug. 10, 2026), First Unum had paid short-term disability benefits before denying Siam Mendoza's claim for long-term disability benefits. Mendoza argued that those earlier payments should create a legal presumption that he remained disabled when the LTD claim was evaluated. The Ninth Circuit rejected that argument.
The court distinguished between evidence and a legal presumption. Citing Muniz v. Amec Construction Management, Inc., 623 F.3d 1290, 1296 (9th Cir. 2010), the Mendoza panel held that Ninth Circuit law does not require a court to presume LTD disability merely because STD benefits were previously paid. But prior payment is not meaningless: relying on Saffon v. Wells Fargo & Co. Long Term Disability Plan, 522 F.3d 863, 871 (9th Cir. 2008), the court explained that prior benefits can still be relevant evidence supporting disability.
Mendoza is an unpublished memorandum disposition and states that it is not precedent except as provided by Ninth Circuit Rule 36-3. Its reasoning is nevertheless useful for understanding the distinction the panel drew between earlier benefit payments as evidence and earlier payments as a binding legal presumption.
What's actually different between STD and LTD?
There is no universal answer. The controlling language is the language of the particular disability plans or policies. In Mendoza, No. 25-3080, the Ninth Circuit specifically noted that the district court did not violate Collier v. Lincoln Life Assurance Co., 53 F.4th 1180 (9th Cir. 2022), by considering differences between First Unum's STD and LTD plans. The memorandum does not say that every STD plan and LTD plan uses different definitions or different evidence requirements.
That makes the actual LTD policy critical. As the Ninth Circuit stated in Mendoza, quoting Armani v. Northwestern Mutual Life Insurance Co., 840 F.3d 1159, 1162–63 (9th Cir. 2016), an ERISA claimant challenging a denial ultimately bears the burden of proving by a preponderance of the evidence that the claimant was disabled under the terms of the plan. An STD approval therefore should not substitute for proving the elements required by the LTD plan.
Can the insurer rely on a doctor who never examined me?
Yes, at least as a categorical matter. In Mendoza, the claimant argued that the district court should have credited physicians who examined him in person over First Unum's medical professionals who reviewed his records. Citing Black & Decker Disability Plan v. Nord, 538 U.S. 822, 825 (2003), the Ninth Circuit stated that courts are not required to give special deference to examining physicians over non-examining physicians.
That does not mean a file review automatically defeats a treating or examining doctor's opinion. In Mendoza, the Ninth Circuit emphasized the particular administrative record, including opinions from some of Mendoza's own experts indicating that his cognitive test performance was within normal limits. The court therefore found no clear error in the district court's weighing of the competing medical opinions.
One distinction matters: Collier v. Lincoln Life, 53 F.4th 1180, 1188 (9th Cir. 2022), was cited in Mendoza for a different ERISA rule — a court reviewing a denial may not simply adopt a newly presented denial rationale first offered in litigation. The examining-versus-file-reviewer rule in Mendoza came from Black & Decker v. Nord.
What should I do differently when moving from STD to LTD?
Do not treat the STD approval as the finish line. Mendoza, No. 25-3080, illustrates that a claimant can receive STD benefits and still lose an LTD claim after competing medical evidence is evaluated. Before an LTD decision is made, identify the LTD plan's actual definition of disability and determine what medical and vocational evidence addresses that definition.
The administrative record also mattered in Mendoza. The Ninth Circuit affirmed because the district court's weighing of the parties' medical experts was grounded in that record. For an ERISA LTD claimant, that makes the quality and completeness of the evidence submitted during the claim and administrative appeal process especially important rather than relying solely on the fact that STD benefits were previously approved.
Case discussed: Mendoza v. First Unum Life Insurance Co., No. 25-3080 (9th Cir. Aug. 10, 2026) (unpublished memorandum disposition). This page provides general information and is not legal advice.
Short-Term Disability Approval and LTD Claims
These answers focus on the Ninth Circuit's August 10, 2026 decision in Mendoza v. First Unum Life Insurance Co., No. 25-3080.
No. In Mendoza v. First Unum Life Insurance Co., No. 25-3080 (9th Cir. Aug. 10, 2026), the Ninth Circuit held that prior payment of STD benefits does not create a legal presumption that the claimant qualifies for LTD benefits. Prior payment can still be relevant evidence of disability.
The LTD claim must be evaluated under the terms governing LTD benefits. In Mendoza, No. 25-3080, the Ninth Circuit held that earlier STD payments did not compel LTD approval and noted that the district court permissibly considered differences between the particular STD and LTD plans.
Yes. Mendoza, citing Saffon v. Wells Fargo & Co. Long Term Disability Plan, 522 F.3d 863, 871 (9th Cir. 2008), distinguished a legal presumption from relevant evidence. Prior disability payments may support a claim even though they do not automatically establish LTD entitlement.
Yes. In Mendoza, No. 25-3080, the Ninth Circuit cited Black & Decker Disability Plan v. Nord, 538 U.S. 822, 825 (2003), for the rule that courts are not required to give special deference to examining physicians over physicians who review the medical records.
No. Mendoza, No. 25-3080, establishes no automatic preference for a file reviewer. The Ninth Circuit upheld the district court's weighing of the particular evidence because that weighing was grounded in the administrative record, including evidence from some of Mendoza's own experts.
Start with the LTD plan's actual definition of disability and submit evidence that addresses that standard rather than relying on the STD approval alone. Mendoza, No. 25-3080, affirmed an LTD denial after the district court compared competing medical reports and found the claimant had not proved disability under the plan.
That raises a separate issue. Mendoza cited Collier v. Lincoln Life Assurance Co., 53 F.4th 1180, 1188 (9th Cir. 2022), for the rule that a district court clearly errs by adopting a newly presented rationale for an ERISA benefit denial. In Mendoza, however, the court concluded the challenged points were subsidiary to a rationale First Unum had already given during the claim process.
Approved for STD, but facing an LTD denial?
Mendoza v. First Unum, No. 25-3080 (9th Cir. Aug. 10, 2026), shows why an STD approval should not be treated as proof that an LTD claim will take care of itself. Dorian Law represents disability insurance claimants nationwide and can review an LTD application, appeal, or denial before applicable deadlines pass.
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